Anti-Slavery and Human trafficking Policy Template for South Africa

An Anti-Slavery and Human Trafficking Policy outlines how organizations prevent modern slavery and human exploitation in their operations and supply chains. In South Africa, these policies align with the Prevention and Combating of Trafficking in Persons Act and support compliance with international labor standards.

The policy sets clear rules for identifying and reporting suspicious activities, protecting vulnerable workers, and conducting due diligence on business partners. It requires staff training, establishes reporting channels, and details how companies respond to potential violations - especially important in sectors like mining, agriculture, and domestic work where forced labor risks are higher under local conditions.

Companies operating in South Africa need an Anti-Slavery and Human Trafficking Policy when expanding their supply chains, entering high-risk industries like agriculture or mining, or working with international partners. This policy becomes essential when hiring contract workers, engaging with labor brokers, or operating in areas where informal labor is common.

The policy proves particularly valuable during supplier audits, tender processes, and when demonstrating compliance with the Prevention and Combating of Trafficking in Persons Act. It's critical for businesses seeking international certifications, responding to stakeholder inquiries about labor practices, or expanding operations into new regions where labor exploitation risks are heightened.

• Basic Compliance Policy: Core version focusing on minimum legal requirements under South African law, suitable for small businesses and startups
• Comprehensive Corporate Policy: Detailed version with extensive due diligence procedures, supplier screening, and remediation protocols for large organizations
• Industry-Specific Policy: Tailored versions for high-risk sectors like mining, agriculture, or construction, with sector-specific risk assessments
• Supply Chain Focus Policy: Emphasizes vendor management, subcontractor obligations, and cross-border trade compliance
• Integrated Management System Policy: Combines anti-slavery measures with broader human rights, labor, and ethical trading frameworks

• Corporate Leadership Teams: Set policy direction, approve final versions, and ensure organizational commitment to anti-slavery measures
• HR Departments: Implement worker screening, training programs, and grievance mechanisms outlined in the policy
• Compliance Officers: Monitor adherence, conduct risk assessments, and coordinate with legal teams on enforcement
• Supply Chain Managers: Apply supplier vetting procedures and maintain documentation of due diligence efforts
• External Contractors: Must comply with policy requirements when working with the organization
• Labor Brokers: Required to demonstrate compliance and maintain transparent recruitment practices

• Supply Chain Assessment: Map your entire supply network, identifying high-risk areas and vulnerable worker populations
• Legal Framework Review: Gather relevant South African legislation, including the Prevention and Combating of Trafficking in Persons Act
• Industry Standards: Collect sector-specific guidelines and international best practices for your industry
• Stakeholder Input: Get feedback from HR, procurement, and operations teams on practical implementation challenges
• Risk Analysis: Document specific slavery and trafficking risks in your operations and supply chains
• Training Needs: Identify which staff groups need detailed policy training and awareness programs

• Policy Scope: Clear definition of covered entities, activities, and geographical reach within South Africa
• Legal Framework: Reference to relevant legislation and international conventions on human trafficking
• Due Diligence Procedures: Detailed processes for supplier assessment and worker screening
• Reporting Mechanisms: Confidential channels for reporting violations and protection for whistleblowers
• Training Requirements: Mandatory staff awareness programs and documentation procedures
• Enforcement Measures: Consequences for violations and remediation processes
• Review Schedule: Timeline for policy updates and compliance assessments

While both policies address ethical business conduct, an Anti-Slavery and Human Trafficking Policy differs significantly from a Compliance and Ethics Policy in several key ways:

• Scope and Focus: Anti-slavery policies specifically target forced labor and trafficking risks, while Compliance and Ethics policies cover broader ethical business conduct including corruption, fraud, and general misconduct
• Legal Framework: Anti-slavery policies align primarily with the Prevention and Combating of Trafficking in Persons Act, while Compliance and Ethics policies reference multiple regulatory frameworks
• Due Diligence Requirements: Anti-slavery policies mandate specific supply chain investigations and worker protection measures, whereas Ethics policies focus on general business conduct standards
• Reporting Mechanisms: Anti-slavery policies require specialized reporting channels for trafficking concerns, while Ethics policies typically use broader whistleblowing systems